FoodDrinkEurope (FDE)

An opponent of the national origin labelling schemes spreading across the bloc, FDE submitted a five-page document with its concerns and recommendations.

For instance, it welcomed the fact that trademarks and protected geographical origins were excluded from the draft regulation “for the time being​”, but said the wording of the text created confusion and it asked for more clarity.

FDE said the draft rules left a number of fundamental questions unanswered and called for an EU guidance or Q&A document to address them.

This included the definition of a primary ingredient in the case of ‘exotic’ primary ingredients that can only be sourced outside the EU, such as cocoa or coffee, or foods that have water as a primary ingredient.

It also asks for clarification on how to approach cases where ingredients have multiple processing steps that could occur in multiple countries, as well as a longer transition period of at least two years.

Requirements on font size were “unnecessarily restrictive and overly prescriptive​” as well as being unnecessary to avoid consumers being misled.